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HomeMy WebLinkAbout08-5440IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. (? Plaintiff No: Sggo &%j;(-Te k vs. COMPLAINT IN CIVIL ACTION ERIC J HEISHMAN Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06916205 C J Pit SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. Civil Action No ERIC J HEISHMAN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CHASE BANK USA, N.A. is a corporation with offices at 3700 WISEMAN BLVD. SAN ANTONIO , TX 78251 . 2. Defendant , is adult individual(s) residing at the address listed below: ERIC J HEISHMAN 317 WOLF BRIDGE RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX4970 4. Defendant made use of said credit card and has a current balance due of $6147.52 . 5. Defendant is in default of the terms of the Cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Cardholder Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00 . Statement for account number: 4266 9411 2563 4970 New Balance Payment Due Date Past Due Amount Minimum Payment ` ' $6,147.52 06/16/08 $943.00 $1,434.52 Amount Enclosed Make your check payable to Cardmember Services. ,.. $ New address or e-mail? Print on back. 426684112563497000143452006147520000008 42009 BEX Z 14309 C ERIC J HEISHMAN 317 WOLF BRIDGE RD CARLISLE PA 17013-8476 III11111111111111111111111111111111111111111111111111111111111 CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 IIIJIIIIIIIIIIIIIIILJII II III IIIJ IIIJ II IIIII III IIIIIIL III 11:5000 L602811: 203 LL 2 56 349 70 5iin Opening/Closing Date: 04/23/08 - 05/22108 CUSTOMER SERVICE \,..,/ Payment Due Date: 06/18108 In U.S. 1-800.136-7903 Minimum Payment Due: $1,434.52 Espafiol 1-888-446-3308 TOO 1.800.955-8060 Pay by phone 1-800-436-7958 Outside U.S. call collect VISA ACCOUNT SUMMARY Account Number: 4266 $4112563 4970 1-302-594-8200 Previous Balance $5,925.61 Total Credit Line $5,900 ACCOUNT INQUIRIES Purchases, Cash, Debits +$78.00 Available Credit $0 P.O. Box 15298 Finance Charges +$143.91 Cash Access Line $1,180 Wilmington, DE 19850-5298 New Balance $6,147.62 Available for Cash $0 PAYMENT ADDRESS P.O. Box 15153 Wilmington, DE 19886-5153 VISIT US AT: www.cardmemberservices Mm You haven't made the required payments and your credit card account is 90 days past due. As a result, your credit bureau may be updated with a negative rating. Please send your payment immediately or call us at 1-800-955-8030 (collect 1-302-594-8200) today. VOLKSWAGEN REWARDS SUMMARY Redeem points for travel, cash, brand-name Previous balance 0 merchandise and more. To redeem your points, Points earned from purchases 0 call 1-866-7284911 or visit Remaining points balance 0 www.cardmemberservioes.com Points unavailable for redemption 5,169 92 Points to expire on statement date in May 2012 TRANSACTIONS Trans Amount Date Reference Number Merchant Name or Transaction Description Credit Debit 05118 LATE FEE $39.00 04/23 OVERLIMIT FEE 39.00 FINANCE CHARGES Finance Charge Daily Periodic Rate Corresp. Average Daily Due To Transaction Accumulated FINANCE Category 30 days in cycle APR Balance Periodic Rate Fee Fin Charge CHARGES Purchases V.07942% 28.99% $5,599.91 $133.42 $0.00 $0.00 $133 42 Cash advances V.07942% 28.99% $0.00 $0.00 $0.00 $0.00 . $0 00 Convenience check V.07942% 28.99% $440.40 $10.49 $0.00 $0.00 . $10.49 Total finance charges $143.91 Effective Annual Percentage Rate (APR): 28.99% Please see Information About Your Account section for balance computation method, grace period, and other important information The Corresponding APR is the rate of interest you pay when you carry a balance on any transaction category. The Effective APR represents your total finance charges - including transaction fees such as cash advance and balance transfer fees - expressed as a percentage. EXHIBIT i This Statement is a Facsimile - Not an original 0000003 FIS33334 C 1 000 N Z 22 0810522 Page 1 of 1 06327 MA MA 42009 14310000010004200901 X 0120 INS13084 A% - Address Change Request Please provide information below only if the address information on front is incorrect. Street Address: -----_--_ City: ----------------- State: -- Zip: ----- Home Phone: --- --- - Work Phone: --- --- --, E-mail Address: -- L Information About Your Account Lost or Stolen Curds: Please report your lost or stolen card immediately by calling the Customer Service number found on the front of your statement. Advisors are always available to assist you. You can reach an Advisor by pressing 0 after you enter your account number. CrediBng of Payrronts: For payments by regular U.S. mall, send at leastyour minimum payment due to our post office box designated for payments shown on this statement. Your payments by mail must comply with the instructions on this statamen4 and must be made by check or money order, payable In U.S. Dollars, and drawn on or payable through a U.S. financial institution or the U.S. branch of a foreign financial instiudon. Do not send cash. Write your account number on your check or money order. Payments must be accompanied by the payment coupon In the envelope provided with our address visible through the envelope window; the envelope cannot contain more than one payment or coupon; and there can be no staples, paper dips, tape or correspondence included with your payment. If your payment is in accordance with our payment instructions and is made available to us on any day except December 25 by 1:00 p.m. local time at our post office box designated for payments on Chia statement, we will credit the payment to your account as of that day. If your payment is in accordance with our payment instructions, but is made available to us after 1:00 p.m. local time at our post office box designated for payments on this statement, we will credit it to your account as of the next day. If you do not follow our payment Instructions or If your payment is not sent by regular U.S. mail to our post office box designated for payments, crediting of your payment maybe delayed for up to 5 days. Payments made electronically through our automated telephone service, Customer Service advisors, or our web site will be subject to any processing times disclosed for those payments. Account Information Rsooded to Credit Bureaus: We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. If you think we have reported inaccurate information to a credit bureau, you may write to us at the Cardmember Service address listed on your billing statement. Notice About Electronic Check Conversion: When you provide a check as payment, you authorize us either to use information from yourcheck to make a one-time electronic fund transfer from your account or to process the payment as a check transaction. When we use informati on from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. Call the customer service number on this statement if you have questions about electronic check collection or do not want your payments collected electronically. Conditional Payments: Any payment check or other form of payment that You send us for less than the full balance due that Is marked "paid in full' or contains a similar notation, or that you otherwise tender In full satisfaction of a disputed amount, must be sent to Card Services, P.O. Box 15049, Wilmington, DE 19550-5049. We reserve all our dghts regarding these payments (e.g., if it is determined there is no valid dispute or if any such check is received at any other address, we may accept the check and you will still owe arry remaining balance). We may refuse to accept any such payment by returning It to you, not cashing it or destroying It All other payments that you make should be sent to the appropriate payment address. Annual Renewal Notice: If your account has an annual lee, it will be billed each year or in monthly installments, whether or not you use your account, and you agree to pay it when billed. The annual fee is non-refundable unless you notify us that you wish to close your account within 30 days of the dam we mail Is an tatemt on which the annual fee le charged and at the same time, you pay your outstanding balance in full. Your payment of the annual fee does not affect our rights to dose your account and to gmltyour right to make transactions on your account. If your account is dosed by you or us, we will conti nue to charge the annual fee until you pay your outstanding balance in full and terminate youraarount relationship. Explanation of Finance Charges: We calculate periodic finance charges, using the applicable periodic rates shown on this statement, separately for each feature (e.g., balance transfer/convenience checks and cash advance checks ("check transaction"), purchases, balance transfers, cash advances, promotional balances or overdraft advances). Please consult your Cardmember Agreement for the features that are applicable to your card. These calculations may combine different categories with the same dally periodic rates. If there is a "V" next to a periodic rate on this statement, that rate may vary, and the index and margin used to determine that rate and its corresponding APR are described in your Cardmember Agreement, as amended. There is a minimum finance charge in any billing cycle in which you owe any periodic finance charges, and a transaction finance charge for each balance transfer, cash advance, or check transaction, in the amounts stated in your Cardmember Agreement, as amended. To get the daily balance for each day of the current billing cycle, we take the begmning balance for each feature, add any new transactions or other debits (including fees, unpaid finance charges and other charges), subtract any payments or credits, and make other adjustments. Transactions are added as of the transaction date, the beginning of the billing cycle In which they are posted to your account or a later date of our choice (except that check transactions are added as of the date deposited by the payee or a later date of our choice). Feature added either on the date of a related transaction, the date they are posted to your account, or she last day of the billing rydo. This gives us that day's daily balance. A credit balance is treated as a balance of zom. If a daily periodic rate applies to any feature, we multiply the daily balance by the daily periodic rate to get your periodic finance charges for that day. We then add these periodic finance charges to your dairy balance to get the beginning balance for the next d%. (If more than one IN periodic rate could apply based on the averse % balance, we will use the daily pedodic ram that applies for the average daily balance amount at the end of the billing cycle to calculate the dally periodic finance charge each day.) To get your total periodic finance charge for a billing cycle when a daily periodic rebels) applies, we add all of the daily periodic finance charges for all features. To determine an average daily balance, we add your daily balances and divide by the number of the days in the applicable billing cycle(s). If you multiply the avera91 daily balance for each feature by the applicable daily periodic rate, and n multiply each of these results by the number of days in the applicable billing cycle(s), and then add all of the results together, the total will also equal the periodic finance charges for the billing cyde, except for minor variations due to rounding. To get your total periodic finance charge for a billing cycle when a monthly periodic rate(s) applies, multiply the average daily balance for each feature by the applicable monthly periodic rate and add the results together. The total will equal the parodic finance charges for the billing cycle, except for minor variations due to rounding. Grace Period (at load 20 days): We accrue periodic finance charges on a transaction, fee, or finance charge from the date it is added to your daily balance until payment in full is received on your account. However, we do not charge periodic finance charges on new purchases billed during a billing cycle If we receive both payment of your New Balance on your current statement by the date and time your payment is due and also payment of your New Galante on your previous statement by the date and time your payment was due. There is no grace period for balance transfers, cash advances, check transactions, or overdraft advances. In addition, if there is a "Qualifying Promotional Financing" section on this statement, you will not inar periodic finance charges on any Remaining Balance that appears In that section If you pay that balance in full by the aDplicebb Expiration Dale. Howowr, it capeca defauA under the terms of your Card member Agreement or any Qualifying Promotional Flnandnp otter, the applicable periodic finance charges will accrue an anyy Remaining Balance as soon cat" billing cycle in Ad the default occurs. To avoid finance charges on new Durdreses when your New Balance includes any Remaining Balance(s) In the Qualifying Promotional Financing section, payyourfull New Balance minus the total of those Remaining Balance(s) by the date and time your payment Is due. However, if your statement shows that a minimum payment is due, we must receive at least that minimum payment by the date and i m 'specified on yourststement, even if your New Balance consists only of Qualifying Promotional Financing balances. For "deferred interest" Qualifying Promotional Financing, periodic finance charges accrue during the promotional period but are not added to your account balance. Instead, they accumulate from billing cycle to billing cycle. If a deferred Interest Qualifying Promotional Financing balance is not paid in full by the applicable Expiration Date, the deferred finance charges will be added to your account as soon as the first day after the Expiration Date. Further, if you default under the terms of your Cardmember Agreement, the deferred finance charges will be added to your account as soon as the date of default. For 'flood payment Qualifying Promotional Financing that permits you to pay for a purchase in a designated number of payments, you will not have a grace period for that balance as each payment includes a portion of the interest owed over the repayment term for that purchase. However, you will have a grace period on other new purchases as described above. BILLING RIGHTS SUMMARY In Can of Errors cr Ouestion About Your Bill: If you think your bill is wrong, or if you need more information about a transaction on your bill, write Cardmember Service on a separate sheet at P.O. Box 15299 Wilmington, DE 19850.5299 as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information. • Your name and account number • The dollar amount of the suspected error • Describe the errorand explain, if you can, why you believe there is an error. If you need more Information, descdbe the Item you are unsure about. You do not have to pay any amount in question while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. While we investigate your question, we cannot report you as delinquent or take action to collect the amount you question. If you have authorized us to pay your credit Gard bill automatically from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment, your letter or call (using the Cardmember Service address or telephone number shown on this statement) must reach us at least three business days before the automatic payment is scheduled to occur. Special Rule for Credit Card Purchases: If you have a problem with the qualify of goods or services that you purchased with a credit card (excluding purchases made with a check), and you have tried in good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or services. You have this protection only when the purchase price was more than $50 and the purchase was made in your home state or within 100 miles of your mailing address. These limitations do not apply if we own or operate the merchant, or if we mailed you the advertisement for the property or services. MA030708 CMAIZM , Cardf6ember Agreement ACCEPTANCE DFTHIS AGREEMENT This agreement governs your credit card accoum with us referenced on the card carrier containing the card forthis account Any use of your account is covered bythis agreement Please read the entire agreement and keep it for your records. You authorize us to pay for and charge your account for all transactions made on your account You promise to pay us for all transactions made on your account as wag as any fees orfmance charges. If this is a joint account each of you, together and individually, is responsible for paying all amounts owed, even if the account is used by only one of you. We may require that you pay the fug amount owed without first asking the other person(s) to pay. Please sign the back of your card when you receive It You wig be bound bythis agreement if you or anyone authorized by you use your account for any purpose, even g you don't sign your card. Whether you use your account or not you will be bound bythis agreement unless you cancel your account within 30 days after receiving your card and you have not used your accoum for any purpose. Throughout this agreement, the words 'we ;'es' and'oue mean Chase Bank USA, N.A., the issuer of your credit card and account The words'yoa','your And'yours' mean all persons responsible for complying with this agreement including the personwho applied for the account and the person to whom we address billing statements, as well as any person who agrees to be liable on the account The word'card• means one ormore cards or other Access devices, such as account numbers, that we have issued to permit you to obtain credit under this agreement USING YOUR ACCOUNT Your account is a consumer account and shag be used orgy for personal, famfiy or household purposes. Unless we ogres or it is required by law, we will not be responsible for merchandise or services purchased or leased through use of your accoum. You promise to use your account only for valid and lawful transactions. For example, internet gambling may be illegal in some pla ces. It is not our responsibility to make sure that you use your account only for permissible transactions, and you will remain responsible for paying for a transaction even if H is not permissible or contemplated under this agreement Types otTransections: • Purabaser. You may use your card to pay for goods or services. • Checkr. We may provide you cash advance checks or balance transfer checks as a wayto use your account We also refer to them in this agreement as a check or checks. You may use a check to pay for goods or services, to transfer balances to your a ceoum, or for other uses we allow. But you may not use these checks to transfer balances to this account from other accounts with us or any of our related companies. Only the person whose name is printed on the check may sign the check. Cash advance checks are treated as cash advances end balance transfer checks are treated as balance transfers except as noted in this agreement or any offer we make to you. We may treat' checks that we call convenience checks as balance transfer checks. However, checks that we call convenience checks and that we indicated to you are subject to the terms for cash advances, may be treated as cash advances and assessed cash advance rates and fees. • Balance Transfers: You may transfer balances from other accounts or loans with other credit card issuers or other lenders to this account or other balance transferswe allow. But you may not transfer balances to this account from other accounts with us or any of our related companies. If a portion of a requested balance transferwill exceed your available credit line, we may process a partial balance transfer up to your available credit line. • Cask Advances: You may use your card to get cash from automatic teller machines, or from financial institutions accepting the card; or to obtain travelers checks, foreign currency, money orders, wire transfers or similar cash-hike charges: Otto obtain lottery tickets, casino gaming chips, race track wagers or for similar betting transactions. You may also use a third party service to make a payment on your behalf and big the payment to this account • Overdraft Advances If you have an eligible checking account with one of our related banks, you may link this account to your checking account with our related bank to cover an overdraft on that checking account under the terms of this agreement and your checking account agreement Billing Cycle-..In ordertomanage your account we divide time into periods called•billing cycles'. Each billing cycle is approximately one monthin length For each calendar month, your account will have a billing cycle that ends in that month. Your account wig have a billing cycle ending in each calendar month whether or pot there is a billing statement for that billing cycle. Autborized Users If you allow someone to USA your account that person will be an authorized user. You may request an additional card for use by on authorized user on your accourd. Byou do so, this account may appear on the creditreportofthat authorized user. You should think carefully before allowing anyone to become on authorized user because you are allowing that person to use the account as you can You wig remain responsible for the use of your account and each card issued Onyouraccount according to the terms of this agreement This includes your responsibility for paying all charges on your account made by an authorized user. You must notify us to terminate on authorized user's permission to use your account if you notify us, we may close the account And/or issue a new card or cards with a different account number. You should 813D recover and destroy any cards, checks or any other moans of access :o your account from that authorized user. Credit Lima: Your credit line appears on Your billing statements. We mayalso refer to the credit fine as a credit limit. Your billing statement may also show that only a portion of your credit line may be used for cash advances. Cash advances, including cash advance checks, are charged against the cash advance portion of your credit fine, and all other transactions are charged against your credit line. You are responsible lot keepir,g track Page 1 of 6 of your account balance, including any fees and finance charges, and making sure it remains below your credit fine. If your account balance is over your credit line for any reason, we may charge you an overfrmitfee as described in this agreement We may, but are not required M, authorize charges that go over your credit line. You must pay any amount over your credit fine, and you must pay us immediately R we ask you to. This agreement applies to any balance on your account, including any balance over your credit line. At our discretion, we may increase, reduce, or cancel your credit One, orthe cash advance portion of your credit fine, at any time. However, if you have asked us not to do so, we wig not increase your credit line. A change to your credit line will not effect your obligation to pay us. international Transactions:. International transactions include any transaction that you make in a foreign currency orthetyou make outside of the United States of America even 'd it is made in U.S. dollars. If you make a transaction in a foreign currency, Visa International or MasterCard International, Inc., will convert the transaction into U.S. dollarsby using its respective currency conversion procedures. The exchange rate each entity uses to concert currency is a rate that it selects either from the range of rates available in the wholesale currency markets for the applicable processing date (which rate may vary from the rate the respective entity itself receives), or the government-mandated rate in effect on the applicable processing date. The rate in effect on the applicable processing date may differtrom the rate on the date you used your card or accoum, We reserve the rightto charge you an additional3% of the U.S. dollar amount of any international transaction, whether that transaction was originally made in U.S. dollars or was made in another currency and converted to U.S. dollars by Visa or MasterCard In either case, the 3% will be calculated on the U.S. dollar amount provided to us by that entity. The same process and charges may apply if any international transaction is reversed. Refusal to Autlrotfze Transactions: We may, but are not required to, decline a transaction on your account for any of the following reasons: • because of opertional considerations, • because your account is in default, • if we suspect fraudulent or unlawful activity or, • in our discretion, for Any other reason. We are not responsible for any losses if a transaction on your account is declined for any reason either by us or a third party, even if you have sufficient credit available. For online tvartactions, we may require that you register your account with an authorization system that we select We will notify you if we want you to register. If you do not register, we may decline your online transactions. Refusal to Pay Checks: Each check you write is your request forfunds. When we receive a check for paymsm, we may review your account to decide whether to authorize that check We may, but are not required to, reject and return unpaid a check for any reason, including the following examples: • We or one of our related companies is the payee on the check. • Your credit line or cash advance portion of your credit line has been exceeded, or would be exceeded ri we paid the check. • The check is post-dated. If a post-dated check is paid, resulting in another check being returned or not paid, we are not responsible. • You have usetf the check after the date specified on it • You are in defau't or would be if we paid the check. Lost or Stolen Cards, Checks or Account Numbers: If any card, check, account number or other means to access your account is lost or stolen, or you think someone used or may use them without your permission, you must notify its at once by calling the Cardmember Service telephone number shown on your card or billing statement. Do not use your account after you notify us, even if your card, check, account number or other means to access your account is found or returned. We may.terminate or suspend your credit privileges when you notify us of any loss,theh or unauthorized use related to your account You may be liable if there is unauthorized use of your account from which you receive no benefit, but you Will not be liable for more than S50.00 of such transactions, and you will not be lisble for any such transactions made Attar you notify us of the loss, theft or unauthorized use. However, you must identify for us tha unauthorized charges from which you received no bmefd. We may require you to provide us information in writing to help us find out what happened. We may also require you to comply with certain procedures in connection with our investigation. PAYMENTS Payment iastructinnst.. Your billing statement and accompanying envelope include instructions you must follow for making payments and sets forth the date and time by which we must receive the payment You agree to pay it. amounts you owe inU.S. dollars drawn on funds on deposit in a U.S. financial iOStbdOn or the U.S. branch of-a foreign financial institution using a payment check, money order or automatic debit that will be processed or honored by your financial institution. We Pali not accept cash payments. Your total available credit may not be restored for up to 35 days after we receive your payment Arty payment check or other form of payment which you send to us for less than the full balance that is marked'paid in fuir or with a similar notation or that you otherwise tender in fug satisfaction of a disputed amount iconditional payments), must be sent to us at the conditional payments address listed on your monthly statement We reserve all our rights regarding such payments For example. if 0 is determined there is no valid dispute or if any such payme:ti is received at any other address, we may accept the payment and you will still owe ony :zmaining balance. We may refuse to accept any such payment by returning it to iRe; not cashing 11 of by destroying it All other payments that you make should be $eat to :t:e regular payment address shown on your monthly statements. EXHIBIT a We reserve the right to electronically collect your eligible payment charks, at first presentment and any representment, from the bank account an which the check is drawn. Dur feceipt of your payment checks is your authorization for us to collect the amount of the check electronically, or, il needed, by a draft drawn against the bank acCDUnt Payment rhecks will be collected electronically by sending the check amount along with the check, routing and account numbers to your bank. Your bank account may be debited as early as the same day we receive your payment The original payment check will be destroyed and an image wig be maintained in our records, lWaiiruam Payment You agree to pay at least the minimum payment due, as shown on your biR'mg statement, so that we receive it by the date and time payment is due. You may pay more than the minimum payment due and may pay the full amount you owe tee at any time. If you have a balance that is subject to finance charges, the sooneryou pay us, the less you Will pay in finance charges because fmance charges accrue on your balance each day. Your billing statement shows your beginning balance and your ending balance (the 'New Balance' on your billing statement). If the New Balance is S1DAD or less, your minimum payment due will be the New Balance. Otherwise, it will be the largest of the fDDowing: MD.W; 2% of the New Balance; or the sum of 1 % of the New Balance, total billed pariadit rate finance charges, and any billed late and Dverlimh fees. As part ofthe minimum payment due, we also add any amount past due and any amount over your credit line. Payment Allocation: You agree that we are authorized to allocate your payments end credits in a way that is most favorable to or convenient for us. For example, you authorize us to apply your payments and credits to balances with lower APRs (such as promotional APRs) before balances with higher APRs. Credit Balances: You may request a refund of a credit balance at any time. We may reduce the amount of any credit balance by the amount of new charges Drfees billed to your account. Automatic Charges: You may authorize a third parry to automatically charge your account for repast transaCt!Dns (for example, monthly utility charges, memberships andinsurance premiums). If automatic charges are stopped for anyreeson (including because your account is closed or suspended for any reason) or your account number changes, you are rosponsible for notifying the biller and paying these charges directly. If your account number changes, we may, but are not required to, pay from your new account number charges that you authorized to be biped to your Did account number. Promotion= From time to time we may offer special terms for your account If we do, we will notify you about the terms of the offer end how long they will be in effect. Any promotion is subject to the terms of this agreement, as modified by the promotional offer. FINANCE CHARGES Daily Periodic Rates and Annual Percentage Rates: Your annual percentage rotes ('APRs') and the corresponding daily periodic rates are listed on the Rates and Fees Table that is at the end of this document or provided separately. To get the daily periodic rate we divide the APR by 365, and in effect always round up at the fifth plats to the right of the decimal point Variable Rates: Dne or more APRs that applyto your account mayvary With the nges to the Prime Rate. When you have an APR that varies with changes to the Prime Rate, we calculate the APR by adding a margin to the Prime Rate published in The WafiStmetJoumaftwo business days before the Closing Date shown on your billing statement The 'Prime Rate' is the highest (U.S.) Prime Rate published in the Money Rates section of The Wall Street JDumaL If The Wall Street Joumalstops publishing the Prime Rate, we will select a similar reference rate and inform you on your billing statement or through a separate notice. A'margin' is the percentage we add to the Prime Rate to calculate the APR. A "business day" is any day that is not a weekend or federal holiday. The Rates and Fees Table shows which rates, if any, are variable rates. It also lists the margin for each variable rate and any minimum daily periodic rate and corresponding APR Two business days before the Closing Date shown on your billing statement, we see what the Prime Rate is. We then add the applicable margin to that Prime Rate to get the APR The daily periodic rate is calculated as described above. If our calculation results in a change to a daily periodic rate from the previous billing cycle because the Prime Rate has changed, the new rate will apply as of the first day of your billing cycle that ends is the calendar month in which we made the calculation. If the daily periodic rate increases, you will have to pays higher periodic finance charge and may have to pay a higher minimum payment Default Rater Your APRs also may vary if you are in default under this agreement or any other agreementyou have with us or any of our related companies for any of the following reasons: • We do not receive, for any payment that is owed on this account or any other account or loan with us, at least the minimum payment due by the date and time due. • You exceed your credit line on this account • You make a payment to us that is not honored by your bank. It any of these events occurs, we may increase the APRs (including any promotional APR) on all balances (excluding overdraft advances) upto a maximum of the default rate stated in the Rates and Fees Table. We may consider the following factors to determine your default rate: the length of time your account has been open, the existence, seriousness and timing of the defaults on your aCCDUnt; other indications of your account usage and performance; information about your other relationships with us or any of our related companies; and information we obtain from consumer credit reports obtained from credit bureaus. The default rate will take effect as of the first day of the billing cycle in which the default occurs. If we decide nutty increase your APR even though there is a default or if we do not increase your APR up to the maximum default rate stated in the Rates and Fees Table, we reserve our right to increase your APR in the event of any future default. We may In our discretion determine to charge reduced default rates or reinstate standard rates for all or selected balances on your account Finance Charge -Calculation - Average Daily Balance Method (Including New Transaetfwrsk We calculate periodic finance charges separately for each balance associated with a different category of transactions (for example, purchases, balance transfers, balance transfer Checks, cash advances, cash advance checks, overdraft advances,and each pramotion)•These calculations may combine different categories with the some dally periodic rates. This is how it works: We calculate periodic finance charges for purchases, balance transfers, balance transfer checks, cash advances, cash advance checks, and overdraft advances by multiplying the daily balance for each of those categories bythe daily periodic rate for each of those categories, each day. You may have overdraft advances only if you have linked this.opcount to a checking account with one of our related banks. We calculate the periodic finance charges for purchases, balance transfers, balance transfer checks, cash advances, and cash advance checks subjecttD a promotional rate the some way, but we use the promotional rate. To get the daily balance for each day for each Category. • We take the beginning balance for that day. • We add to that balance any new transaptions, fees, other charges, and debit adjustments that apply to that category. We -add a new purchase, cash advance, balance transfer Dr overdraft advance, H applicable, to the daily balance as of the transaction date, or a later date of our choice. We add a new cash advance check or balance transfer check to the daily balance as of the date the cash advance check or balance transfer check is deposited by a payee, or a later date of our choice. • We subtract from that balance any payments, credits, or credit adjustments that apply to that category and that are credited as of that day. • We treat a credit balance as a balance of zero. To get the beginning balance for each category for the next day, we add the daily periodic finance charge to the daily balance. If more than one daily periodic rate could apply to a category because the rate for the category may vary based on the amount of its average daily balance, we will use the daily periodic rate that applies for the average daify balance amount at the end of the billing cycle to calculate the daily periodic finance charge each day. This agreement provides for daily compounding of finance charges. To get the total periodic finance charge for the billing cycle, we add all of the daily periodic fmanre charges for each category for each day during that billing cycle. However, if any periodic finance charge is due, we will charge you at least the minimum periodic finance charge stated in the Rates and Fees Table. IONS necessary to add an additional amount to reach the minimum finance charge, we add that amount to the balance for purchases made during the billing cycle. The total finance charge on your account for a billing cycle will be the sum of the periodic finance charges plus any transaction fee finance charges. For each catagorywe calculate an average dally balance (including new transactions) for the billing cycle by adding all your daily balances and dividing that amount by the number of days fn the billing cycle. If you multiply the average daily balance for a cotegorybythe applicable daily periodic rate, and multiply the result bythe number of days in the billing cycle, the total will equal the periodic finance charges for that balance attibumble to that billing Cycle, except for minor variations due to rounding. Grace Period and Accrual of Finance Charges: We accrue periodic finance charges on a transaction, fee, orfinance charge from the date it is added to your daily balance until payment in full is received on your account However, we do not charge periodic finance charges on new purchases billed during a billing cycle if we receive payment of your New Balanre by the date and time your minimum payment is due and we received payment of ypur New Balance on your previous billing statement by the date and time your payment was due. This exception or'grace period' applies only to purchases and does not applyto balance transfers, balance transfer checks, cash advances, cash advance checks or overdraft advances, if applicable. Transaction Fees for Cash Advancer. We may charge you a cash advance fee in the amount stated in the Rates and Fees Table for cash advance checks and cash advances. In addition, il you use p third party service to make a payment on your behalf and the service charges the payment to this account, we may charge a transaction lee for the payment These transaction fees are finance charges. We a dd the fee to the balance for the related category as of the transaction date of rho cash advance. For example, a transaction fee for a cash advance would be added to your cash advance balance. Transaction Fees for Balance Transfers: We may charge you a balance transfer fee in the amount stated in the Rates and Fees Table for balance transfer checks and balance transfers. These transaction fees ire finance charges. We add the fee to the balance for the related Category as of the transaction date of the balance transfer. For example, a transaction fee for a balance transfer would be added to your balance transfer balance. DTHER FEES AND CHARGES We may charge the following fees. The amounts of these fees are listed in the Rates and Fees Table. These fees will be added to the balance for purchases made during the billing cycle. Annual Membership Fee: If your account has an annual membership fee, it will be billed each year or in monthly installments Jas stated in the Rates and Fees Table), whether Or not You use your aCCDunt, and you agree to pay it when billed. The annual Page 2 of 6 CMA12762 membership fee is non-refundable unless you notify us that you wish to close your account within 3O dayp of the date we mail your billing statement on which the annual membership fee is charged and at the same time, you pay your outstanding balance in full. Your payment of the annual membership fee does not affect our right to close your account or limp your right to make transactions on ?•our account If your account is closed by you or us, we will continue to charge the annual membership fee urrbl you pay your outstanding balance in full and terminate your account relationship. Late For. If we do not receive at least the required minimum payment by the date and time it is due as shown on your billing statement for any billing cycle, we may charge the late fee shown in the Rates and Fees Table. If the late fee is based on a balance, we calculate the late fee using the Previous Balance on the current month's statement that shows the late fee. This balance is the same as the New Balance shown on the prior month's statement for which we did not receive at least the required minimum payment by the date and time it was due. Dverlimit Fez: If your account balance is over your credit line at anytime during a billing cycle, even H only for a day, we may charge en everfimit f9114 We may charge this fee even if your balance is Overthe credit fine because of a finance charge orfee we imposed or a transaction we authorized. We WIN not charge more than one overlimit fee for any billing cycle. But we may charge an overiimit fee in subsequent billing cycles, even if no new transactions are made on your account H your account balance still is over your credit fine at any time during the subsequent billing cycles. Remo Payment Fee: If Is) your payment check or similar instrument is not honored, (b) an automatic debit or other electronic payment is returned unpaid, or (c) we must return a payment check because it is not signed or cannot be processed, we may charge a return payment fee. Return Check Fee: If (a) we stop payment on a cash advance check or balance transfer check atyour request or (b) we refuse to pay a cash advance check or balance transfer check we may charge a return check fee. Administrative Fees: If you request a copy of a billing statement, sales draft or other record of your account or H You request two or more cards or any special. services (for example, obtaining cards on an expedited basis), we may charge you for these services. However, we will not charge you for copies of billing statements, sales drafts or similar documents that you request for a billing dispute you may assert against us under applicable law. We may charge, for any services listed above and other services we provide, the fees front time to time in effect when we offer the service. DEFAULT/CDLLECTIDN We may consider you to be in default if any of these occurs: • We do not receive at least the minimum amount due by the date and time due as shown on your billing statement • You exceed your credit fine. • You fail to comply with the terms of this agreement or any agreement with one of our related companies. • We obtain information that causes us to believe that you may be unwilling or unable to pay your debts to us or to others on time. • You file for bankruptcy. • You become incapacitated or in the event of your death. If we consider your account to be in default, we may close your account without notice and require you to pay your unpaid balance immediately. We also may require you to pay interest at the rate of two percent (2%) a month on the unpaid balance when we deem your account to be six or more billing cycles past due. To the extent permitted by law, if you are in default because you have failed to pay us, you will pay our collection costs, attorneys' fees, court costs, and all other expenses of enforcing our rights under this agreement CLOSING YOUR ACCOUNT You may close your account at any time. If you call us to close your Mount, we may require that you confirm your request in writing. We may close your account at any time or suspend your credit privileges at anytime for any reason without prior notice except as required by applicable law. If we close your account We will not be liable to you for any consequences resulting from closing your account or suspending your credit privileges. If you or we close your account you and any authorized users must immediately stop using your account and destroy all cards, checks or other means to access your account or return them to us upon request You will continue to be responsible for charges to your account, even if they are made or processed after your account is closed and you will be required to pay the outstanding balance on your account according to the terms of this agreement In addition, to the extent allowed by low, we may require you to pay the outstanding balance immediately or at any time after your account is closed. ARBITRATION AGREEMENT PLEASE READ THIS AGREEMENT CAREFULLY. IT PROVIDES THAT ANY DISPUTE MAY BE RESOLVED BY BINDING ARBITRATION. ARBITRATION REPLACES THE RIGHT TO GO TO COURT. YDU WILL NOT BE ABLE TD BRING A CLASS ACTION DR OTHER REPRESENTATIVE ACTION IN COURT SUCH AS THAT IN THE FORM OF A PRIVATE ATTORNEY GENERAL ACTION, NOR WILL YOU BE ABLE TO BRING ANY CLAIM IN ARBITRATION AS A CLASS ACTION DR OTHER REPRESENTATIVE ACTION. YOU WILL NOT BE ABLE TO BE PART OF ANY CLASS ACTION OR OTHER REPRESENTATIVE ACTION BROUGHT BY ANYONE ELSE, OR BE REPRESENTED IN A CLASS ACTION OR OTHER REPRESENTATIVE ACTION. IN THE ABSENCE OF THIS ARBITRATION AGREEMENT, YOU AND WE MAY OTHERWISE HAVE HAD A RIGHT DR OPPDRTUNITY TO BRING CLAIMS IN A COURT, BEFORE AJUDGE DR JURY, AND/DR TO PARTICIPATE OR BE REPRESENTED IN A CASE FILED IN COURT BY OTHERS (INCLUDING CLASS ACTIONS AND OTHER REPRESENTATIVE ACTIONS). OTHER RIGHTS THAT YOU WOULD HAVE IF YOU WENT TD A COURT, SUCH AS DISCDVERY OR THE RIGHT TO APPEAL THE DECISION MAY BE MORE LIMITED. EXCEPTAS OTHERWISE PROVIDED BELOW, THOSE RIGHTS ARE WAIVED. BindiogArbitretioft. This Arbitration Agreement is made pursuantto a transaction involving interstate commerce, and shall be governed by and be enforceable under the Federal Arbitration Act (tho "FAA'1, 9 U.S.C. 41.16 as it may be amended. This Arbitration Agreement sets forth the circumstances and procedures under which claims (as defined below) may be resolved by arbitration instead of being litigated in court Parties Covered. For the purposes of this Arbitration Agreement, 'we , "us , and'our' also includes our parent, subsidiaries, offfftates, licensees, predecessors, successors, assigns, any purchaser of your Account, and aB of their officers, directors, employees, agents, and assigns or any and all of them. Additionally,'we', "us' and 'ouf shad include anythird party providing benefits, services, or products in connection with the Account (including but not limited to credit bureaus, merchants that accept any credit device issued under the Account, rewards programs and enrollment services, credit insurance companies, debt collectors, and o6 of their officers, directors, employees, agents and representatives) if, and only II, such a third party is named byyou as a co-defendant in any Claim you assert against us. Claims Covered. Either you or we may, without the other's consent elect mandatory, binding arbitration of any claim, dispute or controversy by either you or us against the other, or against the employees, parents, subsidiaries, affiliates, beneficiaries, agents or assigns of the other, arising iron or relating in any way to the Cardmember Agreement, any prior Cardmember Agreement, your credit card Account or the advertising, application or approval of your Account ("Claiml. This Arbitration Agreement governs all Claims, whether such Claims are based on law, statute, contract, regulation, ordinance, tort, common law, constitutional provision, or any legal theory of law such as respondeat superior, orany otheriegal or equitable ground and whether such Claims seek as remedies money damages, penalties, injunctions, or declaratory or equitable relief. Claims subject to this Arbitration Agreement include Claims regarding the applicability of this Arbitration Agreement ore validity of the entire Cardmember Agreement or any prior Cardmember Agreement This Arbitration Agreement includes Claims that arose in the past, or arise in the present or the future. As used in this Arbitration Agreement, the term Claim is to be given the broadest possible meaning. Claims subjectto arbitration include Claims that are made as counterclaims, cross claims, third party claims, interpieaders or otherwise, and a party who initiates a proceeding in court may elect arbitration with respect to any such Claims advanced in the lawsuit by any party or pasties. As. an exception to this Arbitration Agreement, you retain the right to pursue in a small claims court anV Cisim thatis within that couA's jurisdiction and proceeds on an individual basis. lf a party elects to arbitrate a Claim,the arbitration will be conducted as an individual action. Neither you nor we agree to any arbitration on a class or representative basis, and the arbitrator 6hail have no authority to proceed on such basis. This means that even if a class action lawsuit or other representative action, such as that in the form of a private attorney general action, is filed, arty Claim between us related to the issues raised in such lawsuits will be subject to an individual arbitration claim it eitheryou or we so elect No arbitration will be consolidated with any other arbitration proceeding without the consent of 86 parties. The only Claims that may be joined in an individual action under this Arbitration Agreement are (1) those brought by us against you and any co-applicant, joint cardmember, or authorized user of your Accoum, or your heirs or your trustee in bankruptcy or (2) those brought by you and any co-applicant, joint cardmember, or authorized user of your Account, or your heirs or your trustee in bankruptcy against us. Initiation of Arbitration. The party filing a Claim in arbitration must choose one of the following two arbitration administrators. American Arbitration Association; or National Arbitration Forum.These administrators are independent from us. The administrator does not conduct the arbitration. Arbitration is conducted under the rules of the selected arbitration administrator by an impartial third party chosen in accordance with the rules of the selected arbitration administrator and as may be provided in this Arbitration Agreement Any arbitration hearing that you attend shall be held at a place chosen by the arbitrator or arbitration administrator within the federal judicial district in which you reside at the time the Claim is filed, or at some other place to which you and we agree in writing. You may obtain copies of the current rules of each of the two arbitration administrators, information about arbitration and arbitration fees, and instructions for initiating arbitration by contacting the arbitration administrators as follows: American Arbitration Association, 335 Madison Avenue, Floor 10, New York, NY 1D01746D5, Web site: www.adr.org, BDD-776.7879; or National Arbitration Forum, P.O. Box 5D191, Minneapolis, MN 55405, Web site: www.arbftration-forum.com, SOD-474-2371. Procedures and law applicable in arbitration. A single, neutral arbitrator will resolve Claims. The arbitratorwil either be a lawyerwith at least ten years experience or a retired or former judge. The arbitration will be conducted under the applicable procedures and rules of the arbitration administrator that are in effect on the data the arbitration is filed unless those procedures and rules are inconsistent with this Arbitration Agreement, in which case this Agreement will prevail These procedures and rules may limit the amount of discovery available to you or us. The arbitrator will apply applicable substantive law consistent with the FAA and applicable statutes of limitations, and will honor claims of privilege recognized.et law. You may choose to have a hearing and be represented by counseLThe arbitrator will take reasonable steps to protect customer Account information and other confidential information, including the use of protective orders to prohibit disclosure outside the arbitration, if requested to do so by you or us. The arbitrator will have the power to award to a party any damages or other relief provided for under applicable law, and will not have the power to award relief to, against or for the benefit of any person who is not a party to the proceeding. If the law authorizes such relief, the arbitrator may award punitive damages or attorney fees. The arbitrator will make any award in writing but need not provide a statement of reasons unless requested by a party. Upon a request by you or us, the arbitrator will provide a brief statement of the reasons for the award. Costs. We will reimburse you for the initial arbitration filing fee paid by you up to the amount of S5DO upnn receipt of proof of payment Additionally, if there is a hearing, we Page 3 of 6 CMA12762 will pay shy fees of the arbitrator and arbitration administrator for the firsttwo do of that hearjpg. The payment of any such hearing fees by us will be made direc to the arbitretien administrator selected by you or us pursuant to this Arbitrati Agreement All otherfees will be allocated in keeping with the rules of the arbitrati administrator and applicable law. However, we will advance or reimburse firing fe and other fees if the arbitration administrator or arbitrator determines there is goo reason for requiring us to do so or you ask us and we determine there is good oau for doing so. Eaoh party will bear the expense of the fees and costs of that party attorneys, experts, witnesses, documents and other expenses, regardless of whi party prevalls, for arbitration and any appeal (as permitted belowi, except that t arbitrator shad apply any applicable low in determining whether a party shout recover any or all feet and costs from another party. Enforcement, finality, appeals. Failure or any delay in enforcing this Arbitratio Agreement at anytime, or in connection with anyparticular Claims, will not c°nstitut a waiver of any rights to require arbitration at a later time or in Connection with an other Claims. Any decision rendered in such arbitration proceeding will be final an binding on the panties, unless a party appeals in writing to the arbitration organizatio within 30 days of issuance of the sward. The appeal must request a new arbitratio before a panel of three neutral arbitrators designated by the same arbitratio organization. The panel will reconsider all factual and legal issues anew, follow the some rules that apply to a proceeding using a single arbitrator, and make decisions based on the Vote of the majority. Each party will beer their own fees, costs an and expenses for any appeal, but o party may recover any or all fees, costs and expense from another party, if the majority of the panel of arbitrators, applying applicable low, so determines. An award in arbitration will be enforceable as provided by the FAA or other applicable law by any court having jurisdiction. Severability, survival. This Arbitration Agreement shall survive: (i) termination or changes in the Cordmember Agreement, the Account and the relationship between you and us concerning the Account. such as the issuing of a new account number or the transferring of the balance in the Account to another account; (ii) the bankrupicyof any party or any similar proceeding initiated byyou or on your behalf; and (rTi) payment of the debt in full by you or by a third party. If any portion of this Arbitration Agreement is deemed invalid or unenforceable, the remaining portions shall nevertheless remain in force. CHANGES TO THIS AGREEMENT We can change this agreement at any time, regardless of whether you have access to your act:ount, by adding, deleting, or'modifying any provision. Our right to add, delete, or modify provisions includes financial terms, such as the APRs and fees, and other torts such as the nature, extent, and enforcement of the rights and obligations you or we may have relating to this agreement lulodifcations, additions, or deletions are called 'Changes' or a "Change We will notify you of any Change if required by applicable law. These Changes may be effective with notice only, at the time stated in our notice, in accordance with applicable law. Unless we state otherwise, any Change will apply to the unpaid balances on your account and to new transactions. The notice will describe any rights you may have with respect to any Change, and the consequences if you do or do not exercise those rights. For example, the notice may state that you may notify us in writing by a specified date if you do not want to accept certain Changes we are making. If you notify us in writing that you do not accept the Changes, your account may be closed (if it is not already closed) and you will be obligated to pay your outstanding balance under the applicable terms of the agreement If you do not notify us in writing bythe date stated in the notice, or if you notify us but then use your account after the date stated in the notice, you will be deemed to accept all Changes in the notice and to accept and confirm all terms of your agreement and all Changes in prior notices we have sent you regardless of whether You have access to your account CREDIT INFDRMATION We may periodically review your credit history by obtaining information from credit bureaus and others. We may report information about you and your account to credit bureaus, including your failure to pay us on time. If you request additional cards on your account for others, we may report account information in your name as well as in the names of those other people. If you think we have reported inaccurate information to a credit bureau, you may write to us at the Cardmember Service address listed on your billing statement Please include your name, address, account number, telephone number and a brief description of the problem. If available, please provide a copy of the credit bureau report in question. We will promptly investigate the matter and, if our investigation shows that you are right, we will contact each credit bureau to which we reported the information and will request they correct rho report Il we disagree with you after our investigation, we will tell you in writing or by telephone. We will also notify the credit bureau that you dispute the information unless you let us know that you no longer dispute the information. NDTICES/CHANGE OF PERSONAL INFORMATION We will send cards, biding statements and other notices to you at the address shown in our riles. Or, if this is a joint account, we can send billing statements and notices to any joint account holder. Notice to one of you will be considered notice to all of you and all of you will remain obligated on the account If you change your name, address, or home, cellular or business telephone number or email address (if you elect to receive billing statements or other notices online), you must notify us immediately in writing at the address shown on your billing statement We may, at our option, accept mailing address corrections from the United States Postal Service. We may comact you about your a ec punt, including for customer se rvice or collection, at any address or telephone number as well as any cellular telephone number you provide us. ys TELEPHONE MONITORING AND RECORDING tly, We, and if applicable, our agents, may listen to end record yourtelephone calls with on us. You agree that we, and if applicable, our agents, may do so, whether you or we on initiate the telephone call. es INFORMATIDN SHARING d You authorize us to share certain information about you and your accountwfthin our sa family of companies, and with others outside ourfamily of companies including any s comparryororgan¢atbitwhosenameormarkmayappearonthecards,aspermitted ch by low. Our Privacy Policy, which is provided to you when you first reserve an he agreement andatieastonce each calendar yearthereafteSdescribes ourinformation d sharing practices and the choices you have and directions you may give us about our sharing of information about you and your account with companies or n organizations within and outside of our family of companies. e ILLINDIS CARDMEMBERS dY Illinois low provides that we may not share information about you with companies n or other organizations outside of our family of companies unless you authorize the n disclosure or unless the disclosure falls under another exception in the law (such n as sharing information to process your transactions or in response to a subpoena). e You hereby agree that,ifyouchoosenottoexercisetheapplicableoptoutdescribed s in our Privacy Policy, you will be deemed to have authorized us to share personal information we have about you (including information related to any of the products s or services you may have with any of our companies) with companies or other e organizations outside of our family of companies. ENFORCING THIS AGREEMENT We can delay enforcing or not enforce any of our rights underthis agreement without losing our right to enforce them in the future. If any of the terms of this agreement are found to be unenforceable, all other terms will remain in full force. ASSIGNMENT We may assign your account, any amounts you owe us, or any of our rights and obligations under this agreement to a third party. The person to whom we make the assignment will be entitled to any of our rights that we assign to that person. GOVERNING LAW THETEiMS AND ENFORCEMENT OFTHIS AGREEMENTAND YDUR ACCOUNT SHALL BE GOVERNED AND INTERPRETED IN ACCORDANCE WITH FEDERAL LAW AND, TO THE EXTENT STATE LAW APPLIES, THE LAW OF DELAWARE, WITHOUT REGARD TO CDNFUCT-DF-LAW PRINCIPLES. THE LAW OF DELAWARE, WHERE WE AND YOUR ACCDUNTARE LOCATED, WILLAPPLY NO MATTER WHERE YOU LIVE OR USE THE ACCOUNT. FOR INFORMATION Please call the Cardmember Service telephone number on your card or billing statement If you have any questions about your account or this agreement. YOUR BILLING RIGHTS Keep This Notice For Future Use This notice contains important information about your rights and our responsibilities under the Fair Credit Biding Act Notify Us In Case Of Ermrs Or Questions About Your Bill If you think your bid is wrong, or if you need more information about a transaction on yeurbid, write us on a separate sheet at the Cardmember Service address shown on your billing statement Write to us as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but doing so will not preserve your rights. In your letter, give us the following information: • Your name end account number. • The dollar amount of the suspected error. • Describe the error And explain, P you can, why you believe there is an error. If you need more information, describe the item you are not sure about. If you have authorized us to payyour credit card bill a utomatic ally from your savings or checking account, you can stop the payment on any amount you think is wrong. To stop the payment your letter must reach us at least three business days before the automatic payment is scheduled to occur. Your Rights And Our Responsibilities After We Receive Your Written Notice We must acknowledge your letter within 3D days, unless we have corrected the error by then. Within 9D days, we must either correct the error or explain why we believe the bill was correct After we receive your letter, we cannot try to collect any amount you question, or report you as delinquent We can continue to bill you for the amount you question, including finance charges, and we can apply any unpaid amount against your credit line. You do not have to pay any questioned amount while we are investigating, but you are still obligated to pay the parts of your bill that are not in question. If we find that we made a mistake on your bid, you will not have to pay any finance charges related to any questioned amour If we didn't make a mistake, you may have to pay finance charges, and you wig have to make up any missed payments on the questioned amount In either case, we will send you a statement of the amount you owe and the date that it is due. If you fad to pay the amount that we think you owe, we may report you as delinquent However, N our explanation does not satisfy you and you write to us within 10 days telling us that you still refuse to pay, we must tell anyone we report you to that you have a question aboatyour bill. And, we must tellyou the name of anyone we reported you tD. We musttell anyone we report youto thatthe matter has been settled between us when it finally is. If we don't follow these rules, we can't collect the first SSO.DD of the questioned amount, even if your bill was correct Special Rules for Credit Card Purchases Page 4 of 6 CMA12762 If you have a problem with the quality of property or services that you purchased with a credit card„and you hove tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the property or services. This right does not apply to check transactions. There are two limitations on this right (a) You must have made the purchase in your home state or, if not within your home state, within 1DD miles of your current mailing address, and (b) The purchase price must have been more than SM.M. These limitations do not apply !two own or operate the merchant, or 7 we mailed you the advertisement for the property or services. Copyright 02DO7 JPMorgan.Chase & Co. All rights reserved 3ge5of6 CMA12762 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating to unworn falsifications to authorities, that he/she is Ruben A. Alcaraz (Name) Assistant Treasurer of Chase Bank USA N.A , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR#- 1 I (J QOt) Client Account # _?1 30 Name 4_'_ t-k,l`I?t?n?? N C-n w i r 7 00 •. r cam ,. C SHERIFF'S RETURN - REGULAR CASE NO: 2008-05440 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CHASE BANK USA NA VS HEISHMAN ERIC J WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HEISHMAN ERIC J was served upon the DEFENDANT , at 0948:00 HOURS, on the 17th day of September, 2008 at 317 WOLFS BRIDGE ROAD CARLISLE, PA 17013 MEGAN SIEG, ADULT IN CHARGE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.00 Affidavit .00 Surcharge 10.00 00 40-11o r a 33.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 09/18/2008 WELTMAN WEINBERG REIS By. OK Aa &c- z4z-Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. ERIC J HEISHMAN Defendant No. 08-5440-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan, Esquire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06916205 Judgment Amount $ 13029.35 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 08-5440-CIVIL TERM ERIC J HEISHMAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on arm • 29r--bm 8 (xx) Assumpsit Judgment in the amount of $13029.35 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary O By: PRO ONOT D UTY) ERIC J HEISHMAN 317 WOLF BRIDGE ROAD CARLISLE, PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. Civil Action No. 08-5440-CIVIL TERM ERIC J HEISHMAN Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ERIC J HEISHMAN above named, in the default of an Answer, in the amount of $13029.35 computed as follows: Amount claimed in Complaint $6147.52 Interest from August 27, 2008 to December 4, 2008 $100.04 at the legal interest rate of 6% per annum Attorney's fees TOTAL $300.00 $13029.35 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: t' William T Molczan, Esqui PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06916205 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 317 WOLF BRIDGE ROAD, CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, 'N.A. Plaintiff ERIC J HEISHMAN Defendant(s) IMPORTANT NOTICE TO: ERIC J HEISHMAN 317 WOLF BRIDGE RD CARLISLE,PA 17013f Date of Notice: ? ( "\1 WWR#: 06916205 Case #0 -? L4 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT.A HEARING AND YOU MAY LOSE YOUR-PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY : %7a .- //rn?r?cr?4 w PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. ERIC J HEISHMAN Defendant Case no: 08-5440-CIVIL TERM NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the afftant's belief that the Defendant, ERIC J HEISHMAN is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, ERIC J HEISHMAN is not in the military service. Further Affiant sayeth naught. ? a- AFFIANT n?__ my presence this vl day COMMONWEALTH OF PNNSYLVANIA Notaial 3cea' Heidi J. Kelly, Notary Public City Of Pittsburgh, Allegheny County W Om mission Expires Nov. 4, 2008 Member, Pennsylvania Assoclstlon of Noterles This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center 4D Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 DEC-10-2008 08:23:33 -: Last Name First/Middle Begin Date Active Duty Status Service/Agency HEISHMAN ERIC Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. 14 Abut 14. J04 - * Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htLp://www.defenselink.mil/faq/Tis/PC09SLDR.htrnl WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/10/2008 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BTMPKIIIUSUR https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/10/2008 N G ? c'~ c'3 r?yrri IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. ERIC J HEISMAN Defendant No. 08-5440 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (LEVY ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Moiczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06916205 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. ERIC JHEISMAN , 311 WOW &;O?e Pd Defendant Caf(We, OA /7013 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against ERIC J HEISHMAN, Defendant 3. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): Civil Action No. 08-5440 CIVIL TERM A n01 pooj PO f $ 6547.56 $ 135.62 $ 6683.18 WELTMAN, WEINBERG & REIS CO., L.P.A. By: L? t'? L William T. Molczan, Es ire PA I . D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06916205 FILED- 0 -;_E( E OF THE 2009 KAY 14 PH 4: 17 I`i1, v, *44. 00 3S.00 I'($ . 50 Ko0 A.50 i5a p p AT7Y CBF at to -Pty ATT *a - cx> Coe do .5o LL at:* gU (o e aasI58 t)RT of Fw 46svec f WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5440 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE BANK USA, N.A., Plaintiff (s) From ERIC J. HEISMAN, 317 Wolf Bridge Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell all personal property . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,547.56 Interest -- $135.62 Atty's Comm % Atty Paid $152.00 Plaintiff Paid Date: 5/14109 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs C s R. Lo o onotary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. ERIC J HEISHMAN Defendant(s) No. 08-5440 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. # 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7999 WWR#6916205 CHI IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 08-5440 CIVIL TERM ERIC J HEISHMAN • Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W PAID . #4' WELTM 1400 Ko 436 Sev n (412) dt, Esquire & REIS CO., L.P.A. Building e/Avenue t PA 15219 7999 WWR #6916205 Sworn to and subsc bed before' me th' day of Sep tuber, 09 OF?!`-;=a`? Net nal W41 h Wendy L. Gault fko .""i F < fij }4 City of pitisburgh Al?C.' y NO ARY PUBL M? c()r en p ember, €aennsylva"a s .ssl? Fib E:i)_r=}:',mac OF lli!: P 2099 SLR' 16 PH ! : 2 ! „ `Y '? :?rv ?rnr, n $8.oo Pb AI-N u,-* 4a4 3og4 pTlt a3otoy7 x Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t? OFD . ,.? _-;F1? 20 10A P, I?4 ?iit t?tJ Chase Bank USA, N.A. vs. Eric J Heisman Case Number 2008-5440 SHERIFF'S RETURN OF SERVICE 06/11/2009 09:08 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 11, 2009 at 1833 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Eric J. Heisman, by making known unto Eric J. Heisman, at 317 Wolfs Bridge Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true an( correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard mailed to attorney and letter mailed to defendant on 06-12-09. 07/09/2009 03:42 PM -Sale bill posted on 07-09-09 at 1542 hours by Deputy Fry. Sale date set for Thursday, 08-06-09 at 1500 hours. Copy of sale bill mailed to Attorney Molczan. 08/05/2009 Property sale cancelled via fax from attorney's office 08-05-09. 04/13/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $99.57 April 13, 2010 SO ANSWERS, R- R ANDERSON, SHERIFF 13 afbn R. Larit2 g.?. ra ?d S ???#ass-g C (?OUIt':s SUll!'''>Fe';rifl, TCIBOSOSr, In:i.